Criminal Law - Acid Attack – Section 326A IPC – Conviction Based on Ocular and Medical Evidence – Upheld – Victim was attacked with acid by accused Umesh (Appellant No. 2) while Hakim and Gyani restrained her—Conviction based on consistent testimony of victim and eyewitness supported by medical and documentary evidence—Held: Findings of Trial Court and High Court were plausible and based on proper appreciation of facts—Conviction affirmed [Paras 3–9, 26–27, 33–34].

Criminal Procedure – Delay in Recording Statements – Justified – Defence claimed delay of 11 days in recording statements of victim and eyewitness (PW-6)—Court held delay justified due to victim’s hospitalization and threats to family—Held: No prejudice caused; explanation satisfactory [Paras 28–29].

Evidence – Non-Recovery of Acid – Not Fatal – Appellants argued chemical substance not recovered—Court held recovery impossible as attack occurred near railway crossing and accused fled—Medical evidence confirmed acid burns causing facial disfigurement and loss of vision—Held: Non-recovery immaterial where injury and causation proved [Paras 26–27].

Standard Operating Procedures – Not Mandatory in Acid Attack Cases – Court rejected plea that SOP under acid attack guidelines must be mandatorily followed—Held: Procedural lapses do not vitiate trial unless prejudice shown—Investigation found to be fair [Paras 30].

Sentencing – Mitigating Circumstances – Age and Health – Sentence Reduced for Hakim – Hakim, a 73-year-old retired army personnel with multiple health issues, prayed for parity with third accused who received 10-year sentence—Court allowed appeal partially, reducing Hakim’s life sentence to 10 years RI with ₹50,000 fine [Paras 41–43, 45].

Officer of the Court – Higher Responsibility – Sentence of Advocate Accused Umesh Upheld – Court held advocate’s role aggravated due to position of trust—Letting down the legal fraternity, his life sentence with ₹1 lakh fine upheld—No leniency granted [Para 44].

Decision: Appeal of Hakim (Criminal Appeal No. 5304/2024) partly allowed – Sentence reduced to 10 years RI with ₹50,000 fine. Appeal of Umesh (Criminal Appeal No. 5303/2024) dismissed – Conviction and sentence upheld  [Paras 42–45]

Criminal Law - Sections 7, 13(1)(d) read with 13(2), and Section 20 of the Prevention of Corruption Act, 1988 - Corruption Charges – Demand and Acceptance of Bribe – Proof Required – Acquittal Upheld – Respondent was accused of demanding and receiving ₹1,500 as bribe for submitting a spot inspection report – Trial Court convicted him based on recovery of tainted money – High Court acquitted him citing lack of credible evidence of demand – Supreme Court upheld acquittal, holding demand was not proven beyond reasonable doubt, and testimony of complainant lacked reliability [Paras 1, 6–7, 23–26].

Presumption under Section 20 of Prevention of Corruption Act – Applicability Conditional on Proof of Demand – Rebuttable Presumption Not Triggered – The Court clarified that presumption under Section 20 arises only upon proof of demand – In absence of credible evidence on demand, recovery alone does not sustain conviction – Cited decisions in Paritala Sudhakar and Om Parkash for proposition that presumption cannot substitute proof of demand [Paras 10, 24–25].

Credibility of Complainant – Contradictions and Admissions – Testimony Deemed Unreliable – Complainant denied prior spot inspection, then admitted the same upon confrontation with signed report – Such conduct considered sufficient to reject his testimony as unreliable – Benefit of doubt extended to accused [Paras 24–26].

Final Relief – Acquittal Not Interfered – Appeal Dismissed – Though High Court gave limited reasons for overturning conviction, Supreme Court independently examined the material and found no perversity in acquittal – Held: Chain of demand, acceptance, and recovery was incomplete – Appeal dismissed [Paras 27–29].

Criminal Law - Bail – Section 302, 323, 427, 34, 120B of the Indian Penal Code (IPC) - Grant of Bail in Heinous Crime – Parameters of Judicial Discretion – Bail Cancelled – The Supreme Court set aside the High Court’s order granting bail to the accused in a case involving murder charges under Section 302 IPC – The Court found that the High Court had failed to adequately consider the heinous nature of the offence and the criminal antecedents of the accused, especially when the trial court had rightly refused bail for valid reasons – Held: The cryptic reasoning by the High Court warranted interference, and the Sessions Court’s denial of bail was restored [Paras 13–15, 19–20].

Investigation Stay and Bail – Incompatibility – Prejudice to Trial Process – The accused were granted bail by the High Court even while the trial proceedings remained stayed due to pending proceedings under Section 482 CrPC – The Court found that such simultaneous stay of trial and grant of bail created imbalance and potential prejudice – Held: Continuation of bail in these circumstances was unwarranted and legally untenable [Para 15].

No Reformatio in Peius – Safeguard in Appeal Proceedings – Relevance in Bail Orders – Though not directly reversing an appeal against acquittal or conviction, the Court emphasized that altering status of an accused beneficially without compelling grounds while higher judicial scrutiny is pending undermines fair process – Held: Criminal antecedents and gravity of offence should not have been diluted without detailed justification [Paras 14–15, 19–20].

Appellate Interference – High Court’s Bail Order – Cryptic Reasoning – Supreme Court held that the High Court’s order granting bail lacked reasoned analysis and failed to deal with the gravity of the allegations – The Court reiterated that bail in serious offences must be granted only with due diligence – Held: High Court order set aside and Sessions Court’s order denying bail restored [Paras 19–20].

Final Disposition – Supreme Court Directions – Accused Ordered to Surrender – Supreme Court directed the accused to surrender before the jurisdictional Magistrate or concerned Police Station by 16.06.2025 – Ordered deposit of passports at Police Station Nangal by 19.05.2025 – Held: Appeals allowed and High Court’s order granting bail set aside [Paras 21–23].

Matrimonial Law – Transfer of Matrimonial Case – Divorce by Mutual Consent – Petition under Section 25 CPC – Allowed in part - The Supreme Court exercised its power under Article 142 to dissolve the marriage between the parties despite pending transfer petition – Mutual consent for divorce recorded, and transfer petition was accordingly disposed of [Paras 1-3, 10-11, 20-21].

Article 142 – Divorce by Mutual Consent – Settlement of Ancillary Issues – Liberty Reserved - Though mutual consent for divorce was granted, the petitioner insisted on return of stridhan or alternative monetary compensation – Liberty was reserved to the petitioner to pursue appropriate civil proceedings if Rs. 7,00,000 or stridhan articles are not returned by the respondent within 3 months – Respondent denied retaining stridhan – Court issued enabling direction for resolution while preserving petitioner’s remedies [Paras 6-13, 15-16].

Criminal Proceedings – Section 498A IPC – Quashing on Equitable Grounds – Criminal Complaint Quashed - Given the mutual consent divorce and settlement, the Court quashed the criminal complaint and proceedings under Section 498A IPC filed by the petitioner, holding there was no further purpose in prosecution [Paras 9, 18].

Jurisdiction – Article 142 – Equitable Relief and Complete Justice – Civil and Matrimonial Proceedings Disposed - The Court invoked its extraordinary jurisdiction to ensure complete justice between the parties by dissolving marriage, quashing criminal proceedings, disposing of both matrimonial suits and clarifying liberty to seek civil remedies [Paras 11, 14, 19, 22].

Decision: Transfer petition disposed – Marriage dissolved under Article 142 – Criminal complaint under Section 498A IPC quashed – Liberty granted to petitioner to pursue civil remedies for recovery of stridhan or equivalent compensation [Paras 13-16, 22].

Environmental Law – Ex Post Facto Environmental Clearance – Legality of 2017 Notification and 2021 OM – Held Illegal - The 2017 Notification and 2021 Office Memorandum allowing retrospective environmental clearance were held contrary to statutory and constitutional mandates – The Supreme Court reaffirmed that ex post facto ECs are alien to environmental jurisprudence and violate Article 21 rights to pollution-free environment – Orders struck down for being arbitrary, ultra vires, and inconsistent with binding precedent [Paras 15–20, 26–31, 34–36].

Environmental Jurisprudence – Supreme Court Upholds Precautionary and Polluter Pays Principles – EC Must Be Prior and Not Retrospective - Court reiterated that ECs must be granted prior to project commencement after environmental impact assessment and public hearing – Held: Allowing ex post facto clearances undermines environmental protection and incentivises illegality, flouting principles laid down in Common Cause and Alembic Pharmaceuticals [Paras 16, 17, 29].

Fundamental Rights – Article 21 and 51A(g) – Right to Pollution-Free Environment – Infringed by Post-Facto Regularisation - Held: The 2021 OM undermines the right to life and health and fundamental duty to protect the environment – The State is constitutionally obligated to enforce EC norms strictly; any attempt to dilute such standards through retrospective regularisation is violative of fundamental rights [Paras 32–34].

Judicial Undertaking – Central Government Bound by Statement Before Madras High Court – Estoppel Applies - Union’s undertaking in Puducherry Environment Protection Association case that 2017 Notification was a one-time measure was binding – Court deprecated subsequent circulars and extensions in contravention of judicial declarations and government assurances [Paras 21–22].

Decision – 2017 Notification and 2021 OM Struck Down – Government Restrained from Future Ex Post Facto ECs - Held: 2017 Notification and 2021 OM are illegal and void – Supreme Court restrained the Central Government from issuing any future circulars or memoranda providing for ex post facto EC – However, ECs already granted under these instruments till date are not disturbed [Paras 35–36].

Civil Law - Execution of Decree – Successive Execution Petitions – Satisfaction Recorded in Prior EP Not a Bar – Fresh EP Maintainable on Subsequent Interference - Held: Recording of satisfaction in an earlier EP due to absence of decree-holder and written statement by judgment-debtor cannot bar future EP if fresh breach is alleged – Res judicata not attracted where new cause arises [Paras 2–4, 6].

Limitation – No Bar to Execution of Decree Granting Perpetual Injunction – Article 136 of Limitation Act – Perpetual Right of Decree-Holder - Supreme Court held that there is no limitation for execution of a decree granting permanent injunction – Right to seek enforcement survives perpetually against judgment-debtor, their assignees or successors whenever breach occurs [Para 7].

Civil Procedure – Objection under Section 47 CPC – Consideration Deferred to Executing Court – Only Prima Facie Observations Made - Apex Court clarified that its observations regarding objections under Section 47 CPC are prima facie – Objections can be re-agitated before Executing Court which shall decide afresh including claims about cancellation proceedings [Para 8].

Decision – High Court and Lower Courts’ Orders Set Aside – Execution Petition Restored - Supreme Court set aside all impugned orders and restored EP No. 2 of 2012 – Matter remanded to Executing Court for fresh consideration on merits, except on validity of decree which stands untouched [Paras 8–9].

Criminal Procedure – Inherent Powers under Section 482 CrPC – High Court Cannot Recall Quashing Order – Held Without Jurisdiction - The Supreme Court held that once a final judgment quashing an FIR is passed, it cannot be recalled under Section 482 CrPC due to the bar under Section 362 CrPC – High Court exceeded jurisdiction by reviving a quashed FIR on grounds of compromise violation – Review or recall of final orders not permissible except for clerical or arithmetical errors [Paras 9–12, 14].

Criminal Law – Compromise Between Parties – Breach of Terms No Ground for Criminal Revival – Alternate Legal Remedies Available - Breach of compromise terms does not justify revival of quashed criminal proceedings – Held: Remedy for enforcement lies in civil proceedings or appropriate forums, not through recall of a concluded criminal order [Para 12].

Judicial Discipline – Section 362 CrPC – Recall Power Limited to Clerical Corrections – Law Reiterated - Court reiterated that once a final judgment is signed, courts become functus officio – Inherent power cannot override express prohibition in Section 362 CrPC – Exceptions allowed only in cases involving jurisdictional error, natural justice violations, or fraud [Paras 9.3.2–9.3.4, 10.1, 14].

Decision – Appeals Allowed – High Court’s Orders Recalled – Quashing Restored - Held: High Court acted without legal authority in reviving FIR – Supreme Court set aside all impugned orders and restored original quashing – Registry directed to circulate judgment to High Courts to prevent such procedural errors in future [Paras 13–16].

Society and Trust Law – Religious Property Ownership Dispute – ISKCON Bangalore vs. ISKCON Mumbai – Long-standing dispute over title and management of ISKCON Bangalore resolved – Supreme Court held that ISKCON Bangalore, a registered Karnataka society, is the absolute titleholder of Schedule ‘A’ land allotted by Bangalore Development Authority (BDA) – Held: No legal basis to the claim of ISKCON Mumbai over said property via an unincorporated branch – High Court’s findings contrary to documentary evidence and thus set aside [Paras 33–51, 55–57].

Documentary Evidence – Land Allotment and Registered Sale Deed – Application for BDA allotment (Exh. P-51) made in name of ISKCON Bangalore, signed by its President – Sale deed dated 3rd August 1988 executed in favour of ISKCON Bangalore – All communications, payments, and ULC exemption corresponded to ISKCON Bangalore – No competing application from ISKCON Mumbai or proof of benami transaction produced – Held: Valid title passed to ISKCON Bangalore [Paras 44–51].

Statutory Interpretation – Section 38B BDA Act – Only societies registered under Karnataka Societies Registration Act or trusts under MPT Act eligible for BDA allotment – ISKCON Bangalore, being a registered society, legally eligible – No evidence of ISKCON Mumbai applying under trust provisions – High Court erred in overlooking statutory eligibility and clear application trail [Paras 52–54].

Branch Status and Legal Entity – No Independent Existence of “ISKCON Mumbai, Bangalore Branch” – ISKCON Mumbai failed to produce incorporation documents or authority letters – Application, sale deed, and ULC exemption made only by ISKCON Bangalore – Held: Mere reference to branch functioning does not confer legal title or ownership – Branch lacked legal personality to hold property [Paras 50–51].

Adverse Inference – Key Witness Withheld – ISKCON Mumbai did not produce Stoka Krishna Dasa, alleged source of manipulation claims – Court held that non-examination of material witness warranted adverse inference – Held: Allegations of fraud and manipulation unsubstantiated in absence of direct testimony [Para 47].

Procedural History – Trial Court Decree in Favour of ISKCON Bangalore Restored – High Court Judgment in RFA No. 421 of 2009 reversed – All related appeals rendered infructuous – Oversight Committee managing temple to be dissolved after one month [Paras 56–58, 73(d)].

Internal Governance Dispute – Governing Body of ISKCON Bangalore – Suit No. 1758 of 2003 by members claiming to be rightful management dismissed – Concurrent findings by Trial Court and High Court accepted – Annual General Meeting of 1 July 1984 validly elected new governing body – Plaintiffs’ evidence found weak, contradictory and largely withdrawn – Held: No interference warranted in findings of fact [Paras 59–70].

Decision: Civil Appeal Nos. 3821–3822 of 2023 dismissed – Civil Appeal No. 9313 of 2014 allowed – High Court findings in RFA No. 421 of 2009 set aside – Decree in Suit No. 7934 of 2001 in favour of ISKCON Bangalore restored – Oversight Committee dissolved after one month – All connected appeals disposed of as infructuous – No order as to costs [Paras 73–74].

Civil Writ - Judicial Administration – Creation and Role of Court Managers – Thirteenth Finance Commission Recommendation – Approved - The Court Managers were introduced to improve court efficiency by supporting administrative functions, allowing judges to focus on adjudication – The Finance Commission allocated Rs. 300 crore for the scheme – Guidelines were issued by the Ministry of Finance prescribing the roles, qualifications, and functions of Court Managers – Implementation varied widely across States and High Courts, leading to disparity and ad hoc employment practices [Paras 5–12, 28–30].

Service Conditions – Contractual Appointments and Disparity in Pay – Non-Uniform Practices – Criticized - Most Court Managers were appointed on a contractual basis with no consistent service rules or benefits – The Supreme Court had earlier directed regularization (2018 judgment) – The SNJPC reiterated this need and recommended uniformity, higher pay, and structured recruitment and promotion avenues – Found that several High Courts and State Governments failed to act on the earlier directions [Paras 12–17, 31–36].

Model Framework – Assam Rules of 2018 – Adopted as Model – Recognized - The Court endorsed the Gauhati High Court’s 2018 Rules as a comprehensive model for adoption across jurisdictions – The Rules include regular appointments, clear duties, promotional avenues, and benefit structures – Other High Courts directed to take these Rules as a base with necessary modifications [Paras 39–42].

Directions Issued – Uniformity, Regularization, and Suitability Test – Mandated - All High Courts directed to frame or amend rules for Court Managers within 3 months based on Assam Rules – State Governments to approve within 3 additional months – Suitability tests to be conducted for existing Court Managers; those qualifying to be regularized with retrospective seniority but without arrears – Registrar Generals and Chief Secretaries made personally responsible for compliance [Paras 43–44].

Decision – Writ Petitions and IAs Disposed – Directions Binding - The Supreme Court disposed of the writ petitions and applications with binding directions to ensure regularization and standardization of the Court Manager system nationwide [Para 44].